Diaz et al v. Wells Fargo Bank, N.A. et al

Filing 7

ORDER Granting re 6 Stipulation To Extend Time to Respond To Complaint filed by Wells Fargo Bank, N.A.. Signed by Judge Joseph C. Spero on 3/17/15. (klhS, COURT STAFF) (Filed on 3/17/2015)

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Robert A. Bailey (#214688)
[e-mail]
Steven R. Telles (#246514)
[e-mail]
ANGLIN, FLEWELLING, RASMUSSEN,
CAMPBELL & TRYTTEN LLP
199 South Los Robles Avenue, Suite 600
Pasadena, California 91101-2459
Tel: [phone] | Fax: [phone]
Attorneys for Defendant
WELLS FARGO BANK, N.A.
(“Wells Fargo”)

A NGLIN F LEWELLING R ASMUSSEN C AMPBELL & T RYTTEN LLP

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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YADIRA DIAZ, an individual; ALEX
DELGADO BASTIDAS, an individual;

CASE NO.: 3:15-CV-01150-JCS

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Plaintiffs,
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JOINT STIPULATION TO EXTEND TIME
TO RESPOND TO COMPLAINT

v.

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WELLS FARGO BANK, N.A., CALWESTERN RECONVEYANCE, LLC;
TRIDENT FINANCIAL GROUP, INC. and
DOES 1 through 20, inclusive,
Defendants.

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TO THE HONORABLE COURT:
Plaintiffs, YADIRA DIAZ and ALEX DELGADO BASTIDAS (“Plaintiffs”), and

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defendant, WELLS FARGO BANK, N.A., successor by merger with Wells Fargo Bank

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Southwest, N.A., formerly known as Wachovia Mortgage, FSB, formerly known as World

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Savings Bank, FSB (“Wells Fargo”), through their counsel of record, submit the following

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stipulation to extend time to respond to the Complaint pursuant to N.D. Cal. Local Rule 6-1(a). A

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Court Order is not required at this time since this stipulation will not alter the date of any event

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or any deadline already fixed by Court Order.
93000/FR1539/01099195-2

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JOINT STIPULATION TO EXTEND TIME

RECITALS

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WHEREAS, on February 6, 2015, Plaintiffs commenced an action entitled as

captioned above, in the Superior Court of the State of California, County of San Mateo, Case

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No. CIV532437;

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WHEREAS, Wells Fargo was served with the Complaint on February 9, 2015;

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3.

WHEREAS, Defendant Wells Fargo removed the action to this Court;

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4.

WHEREAS, the parties agree that Wells Fargo’s deadline to respond to the

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Complaint is extended until April 1, 2015; and
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WHEREAS, this stipulation waives no rights of any parties.
STIPULATION

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IT IS HEREBY STIPULATED, that the deadline for Wells Fargo to respond to the
Complaint is extended 14 days from March 18, 2015 to April 1, 2015.

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ATTESTATION PURSUANT TO GENERAL ORDER 45

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I, Steven R. Telles, attest that concurrence in the filing of this document has been

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obtained from each signatory. I declare under penalty of perjury under the laws of the United

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States of America that the foregoing is true and correct. Executed this day of March 16, 2015.

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Dated: March 16, 2015

RT

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Dated: March 16, 2015

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R NIA

By: /s/ Steven R. Telles
Steven R. Telles
[e-mail]
Spero
seph C.
Judge Jo
Attorneys for Defendant
WELLS FARGO BANK, N.A., successor by merger
ER
with Wells Fargo Bank Southwest, N.A., formerly
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N
F
D I S T I C T O known as Wachovia Mortgage, FSB, formerly known
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as World Savings Bank, FSB (“Wells Fargo”)

H

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D
RDERE

FO

NO

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Dated: 3/17/15

OO
IT IS S

LI

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ISTRIC
ES D
T C ANGLIN, FLEWELLING, RASMUSSEN,
AT
T
CAMPBELL & TRYTTEN LLP

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UNIT
ED

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RT
U
O

A NGLIN F LEWELLING R ASMUSSEN C AMPBELL & T RYTTEN LLP

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NICK PACHECO LAW GROUP, APC
By: /s/ Nick Pacheco
Nick Pacheco, Esq.
[e-mail]
Attorneys for Plaintiffs
YADIRA DIAZ and ALEX DELGAGO BASTIDAS

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93000/FR1539/01099195-2

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JOINT STIPULATION TO EXTEND TIME

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CERTIFICATE OF SERVICE

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I, the undersigned, declare that I am over the age of 18 and am not a party to this action.
I am employed in the City of Pasadena, California; my business address is Anglin, Flewelling,
Rasmussen, Campbell & Trytten LLP, 199 S. Los Robles Avenue, Suite 600, Pasadena,
California 91101-2459.

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On the date below, I served a copy of the foregoing document entitled:

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JOINT STIPULATION TO EXTEND TIME TO
RESPOND TO COMPLAINT

A NGLIN F LEWELLING R ASMUSSEN C AMPBELL & T RYTTEN LLP

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on the interested parties in said case as follows:

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Served Electronically Via The Court’s CM/ECF System:
Counsel for Plaintiffs
Yadira Diaz and Alex Delgado Bastidas

Counsel for Defendant
Cal-Western Reconveyance, LLC
[Courtesy Copy]

Nick Pacheco, Esq.
NICH PACHECO LAW GROUP, APC
15501 San Fernando Mission Blvd., #110
Mission Hills, CA 91345

Melissa N. Armstrong, Esq.
BUTLER & HOSCH, P.A.
525 E. Main Street
El Cajon, California 92020

Tel: [phone] | Fax: [phone]
Email: [e-mail]

Tel: [phone] | Fax: [phone]
Email: [e-mail]

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I declare under penalty of perjury under the laws of the United States of America that
the foregoing is true and correct. I declare that I am employed in the office of a member of the
Bar of this Court, at whose direction the service was made. This declaration is executed in
Pasadena, California on March 16, 2015.

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/s/ Marianne Mantoen
(Signature of Declarant)

Marianne Mantoen
(Type or Print Name)

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93000/FR1539/01099195-2

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CERTIFICATE OF SERVICE